PPWR: the new EU packaging regulation enters into application and strengthens companies' obligations
PPWR 2026: which companies are affected?
Since 12 August 2026, Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR (Packaging and Packaging Waste Regulation), has applied in the European Union (EU). This new regulatory framework marks a major development for companies that manufacture, import, distribute or use packaging on the European market.
Manufacturers, importers, distributors and non-EU companies
The PPWR applies to any entity that designs, manufactures, imports, distributes or sells a packaged product on the European market, including companies located outside the EU where a packaged product reaches a final customer in the Union. It introduces new requirements concerning chemical composition, recyclability, the incorporation of recycled materials, minimisation, reuse and labelling.
While some obligations have already applied since August 2026, others will gradually enter into application between 2028 and 2040. Companies therefore need to anticipate now the developments likely to affect packaging design and regulatory compliance.
Stricter requirements for packaging composition and design
One of the main new features of the PPWR concerns the control of substances of concern present in packaging. Article 5 requires their presence and concentration to be minimised, taking into account, in particular, the risks associated with recycling and waste management.
The Regulation maintains a limit of 100 mg/kg for the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components, subject to the applicable derogations.
It also introduces, from 12 August 2026, a specific restriction on per- and polyfluoroalkyl substances (PFAS) in packaging intended to come into contact with food.
Recyclability, recycled materials and packaging reduction: progressive PPWR deadlines through 2040
The PPWR requires a gradual transformation of packaging design in order to improve recyclability and reduce the consumption of virgin raw materials.
PPWR recyclability target from 2030
From 2030, subject to the timetable for the adoption of delegated acts, packaging will have to achieve at least recyclability performance class C, corresponding to recyclability of at least 70% according to the methodology laid down in the Regulation. From 2038, only classes A and B, corresponding to recyclability of at least 80%, will in principle be permitted, subject to the exemptions provided for.
Stricter requirements from 2040
The Regulation also sets minimum recycled content rates for plastic packaging from 2030, differentiated according to packaging category and use. These targets will be strengthened in 2040. Certain categories, particularly packaging intended for sensitive uses, benefit from exemptions or specific provisions.
In parallel, Article 10 introduces obligations to minimise the weight and volume of packaging. From 2030, the empty space ratio will in particular be limited to 50% for certain grouped, transport and e-commerce packaging.
The Regulation also provides for reuse targets, particularly for transport packaging, as well as restrictions on certain single-use plastic packaging formats.
These developments will require a reassessment of the materials used, packaging formats and, in some cases, logistics systems.
Harmonised labelling and new requirements for demonstrating compliance
Harmonised labelling from 2028
The PPWR also provides for the introduction of a harmonised packaging labelling system to facilitate waste sorting across the European Union.
From 12 August 2028, or 24 months after the entry into force of the relevant implementing acts if that date is later, packaging falling within the scope of this obligation will have to bear a harmonised label indicating its material composition, subject to the exceptions provided for in the Regulation.
Documentation obligations to strengthen material traceability
Beyond the technical requirements, the PPWR strengthens the documentation obligations of economic operators. Manufacturers must in particular draw up technical documentation demonstrating the compliance of packaging with the applicable requirements and, where required, an EU declaration of conformity.
These obligations require improved traceability of materials and of the information transmitted throughout the supply chain.
PPWR: what are the implications for companies?
Anticipating extended producer responsibility (EPR) obligations
The application of the PPWR represents a structural change for companies placing packaged products on the European Union market.
Beyond material compliance, operators will need to identify the obligations applicable to them according to their role in the supply chain, particularly as manufacturers, importers, distributors or producers subject to extended producer responsibility (EPR) schemes.
Map your packaging and verify compliance
Preparing for these new requirements involves, in particular, mapping the packaging used, checking its chemical composition, assessing its recyclability and anticipating the design changes that may be required. Companies will also need to review their registration, declaration of conformity and EPR financing obligations in the Member States concerned.
Finally, several technical arrangements still depend on the adoption of delegated or implementing acts by the European Commission. In particular, the methodologies for assessing recyclability, calculating recycled content and the harmonised labelling arrangements remain key points to monitor.
Companies now face a dual challenge: ensuring compliance with the requirements already applicable since August 2026 and anticipating the next regulatory deadlines, particularly those in 2028 and 2030.
Anticipate your PPWR compliance
Our experts can support you in particular with:
- mapping your packaging and your roles in the supply chain;
- analysing its composition and identifying regulated substances;
- assessing requirements relating to recyclability, recycled content, minimisation and reuse;
- checking your obligations regarding labelling, technical documentation and declarations of conformity;
- anticipating the 2028, 2030 and 2040 deadlines;
- defining the priority actions to be implemented.
👉 Need to assess the impact of the PPWR on your packaging? Contact our experts to structure your compliance roadmap.
PPWR 2026: which companies are affected?
Since 12 August 2026, Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR (Packaging and Packaging Waste Regulation), has applied in the European Union (EU). This new regulatory framework marks a major development for companies that manufacture, import, distribute or use packaging on the European market.
Manufacturers, importers, distributors and non-EU companies
The PPWR applies to any entity that designs, manufactures, imports, distributes or sells a packaged product on the European market, including companies located outside the EU where a packaged product reaches a final customer in the Union. It introduces new requirements concerning chemical composition, recyclability, the incorporation of recycled materials, minimisation, reuse and labelling.
While some obligations have already applied since August 2026, others will gradually enter into application between 2028 and 2040. Companies therefore need to anticipate now the developments likely to affect packaging design and regulatory compliance.
Stricter requirements for packaging composition and design
One of the main new features of the PPWR concerns the control of substances of concern present in packaging. Article 5 requires their presence and concentration to be minimised, taking into account, in particular, the risks associated with recycling and waste management.
The Regulation maintains a limit of 100 mg/kg for the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components, subject to the applicable derogations.
It also introduces, from 12 August 2026, a specific restriction on per- and polyfluoroalkyl substances (PFAS) in packaging intended to come into contact with food.
Recyclability, recycled materials and packaging reduction: progressive PPWR deadlines through 2040
The PPWR requires a gradual transformation of packaging design in order to improve recyclability and reduce the consumption of virgin raw materials.
PPWR recyclability target from 2030
From 2030, subject to the timetable for the adoption of delegated acts, packaging will have to achieve at least recyclability performance class C, corresponding to recyclability of at least 70% according to the methodology laid down in the Regulation. From 2038, only classes A and B, corresponding to recyclability of at least 80%, will in principle be permitted, subject to the exemptions provided for.
Stricter requirements from 2040
The Regulation also sets minimum recycled content rates for plastic packaging from 2030, differentiated according to packaging category and use. These targets will be strengthened in 2040. Certain categories, particularly packaging intended for sensitive uses, benefit from exemptions or specific provisions.
In parallel, Article 10 introduces obligations to minimise the weight and volume of packaging. From 2030, the empty space ratio will in particular be limited to 50% for certain grouped, transport and e-commerce packaging.
The Regulation also provides for reuse targets, particularly for transport packaging, as well as restrictions on certain single-use plastic packaging formats.
These developments will require a reassessment of the materials used, packaging formats and, in some cases, logistics systems.
Harmonised labelling and new requirements for demonstrating compliance
Harmonised labelling from 2028
The PPWR also provides for the introduction of a harmonised packaging labelling system to facilitate waste sorting across the European Union.
From 12 August 2028, or 24 months after the entry into force of the relevant implementing acts if that date is later, packaging falling within the scope of this obligation will have to bear a harmonised label indicating its material composition, subject to the exceptions provided for in the Regulation.
Documentation obligations to strengthen material traceability
Beyond the technical requirements, the PPWR strengthens the documentation obligations of economic operators. Manufacturers must in particular draw up technical documentation demonstrating the compliance of packaging with the applicable requirements and, where required, an EU declaration of conformity.
These obligations require improved traceability of materials and of the information transmitted throughout the supply chain.
PPWR: what are the implications for companies?
Anticipating extended producer responsibility (EPR) obligations
The application of the PPWR represents a structural change for companies placing packaged products on the European Union market.
Beyond material compliance, operators will need to identify the obligations applicable to them according to their role in the supply chain, particularly as manufacturers, importers, distributors or producers subject to extended producer responsibility (EPR) schemes.
Map your packaging and verify compliance
Preparing for these new requirements involves, in particular, mapping the packaging used, checking its chemical composition, assessing its recyclability and anticipating the design changes that may be required. Companies will also need to review their registration, declaration of conformity and EPR financing obligations in the Member States concerned.
Finally, several technical arrangements still depend on the adoption of delegated or implementing acts by the European Commission. In particular, the methodologies for assessing recyclability, calculating recycled content and the harmonised labelling arrangements remain key points to monitor.
Companies now face a dual challenge: ensuring compliance with the requirements already applicable since August 2026 and anticipating the next regulatory deadlines, particularly those in 2028 and 2030.
Anticipate your PPWR compliance
Our experts can support you in particular with:
- mapping your packaging and your roles in the supply chain;
- analysing its composition and identifying regulated substances;
- assessing requirements relating to recyclability, recycled content, minimisation and reuse;
- checking your obligations regarding labelling, technical documentation and declarations of conformity;
- anticipating the 2028, 2030 and 2040 deadlines;
- defining the priority actions to be implemented.
👉 Need to assess the impact of the PPWR on your packaging? Contact our experts to structure your compliance roadmap.
